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We are currently in the middle of our first round of external audits to ISO45001 and ISO14001, the end of a tough 3 year program. So far its going well!

One thing that has arisen at one site is that one of the auditors is stating that each of our sites globally should/must have a significant aspect identified. I can understand this for some larger sites but some sites are just offices with very little environmental impact.

The standard asks that we identify aspects, have a scoring system to ascertain significance but I dont see anything that states that each site should/must have a significant aspect.

Indeed it doesn't really state that you should have significant aspects although obvioulsy for some operations you would.

Does anyone have any experience of this that could maybe provide some guidance?

We have literally had this same issue raised at our last audit and closed it out by identifying our most significant aspects on a site by site basis then conducting a life cycle evaluation if it. For instance waste packaging reviewed incorporating design, procurement of materials, manufacture, sale (packaging onto the market place) and dispoal / recycling opportunities.

In order to determine our most significant aspects we reviewed our aspects register and added a scoring system for Severity, Control & Quantity 1-5 (5 highest). We multipled the results by each other e.g. 2 x 2 x 2 = 8. Then ranked them. Those that come out the highest are most significant. Auditor was happy.

In an office the most significant aspect may be paper useage, toner, electricity or general waste etc etc..

Yes, thats the approach we already have in place, we score each using a system and then set a level for which anything above say a score of 8 was classed as significant. Auditors are fine with this but are saying that we should have someone above 8 (significant) at each location. It may just a simple play on words and how we/they understand what significant means.

We are not a big environmental impacter and some of our small locations are just a few people in an office.

Yes, thats the approach we already have in place, we score each using a system and then set a level for which anything above say a score of 8 was classed as significant. Auditors are fine with this but are saying that we should have someone above 8 (significant) at each location. It may just a simple play on words and how we/they understand what significant means.

We are not a big environmental impacter and some of our small locations are just a few people in an office.

best thing to do is ask them for the clause that states that you should have at least 1 significant aspect for each site......

14004-2016 Section 6.1.2.5 give good guidance on this. If you can get a copy of it put it in front of the auditor and ask them to justify their position based on that guidance. Don't be shy, push back, its your management system not theirs they are there to make validate it against the standard not to create additional workload for you. How credible would your function be if you had to class the disposal of empty tipex bottles as a significant aspect that needs a licenced hazardous waste carrier to come at cost to dispose of that one bottle every six months.

As long as you have a prcocess and set your limits/criteria you can show weather or not you have significant aspects if you do you will have some actions, if you don't that's fine too as long as you periodically review it....

ISO14001 states at Clause 6.1.2 - Within the defined scope of the EMS, the organisation shall determine the environmental aspects (hazards) of its activities.

I would therefore suggest that you consider what the scope and area of coverage is of your EMS. You may be able to produce one overall aspects & impacts register and assessment, whereby you can determine locations of each, as this is a requirement under the clause.

The clause continues that you should maintain documented information of aspects & impacts - perhaps use Legislation Update Service, where this is inclusive?

Seems to be a strange situation in which our audit body have never had a multi-site where not all sites have significant aspects. They have gone back to their body for guidance but for the moment, it looks like we have got an impasse.

Like I said, reality is we are a very low impacter on the environment but as we are going for 45001, made sense to do 14001 at the same time.

Sounds like the auditors have gone off on one. If this is the only real issue identified then it sounds like you have your Aspects and Impacts nailed down. I suggest thay you feed the bear - just ID one "most significant" aspect using your stated crieria and they will be happy.

I agree with Pikeman, some auditors appear to have made up their own rules around what is said in standards and what is the actual requirement. For example last year I had an auditor from a major assessment body argue that we did not have a sufficently high number of interested parties, the same person said that we did not have a sufficently high number of significant aspects and impacts. He appeared surprised when I pushed back and would not accept what he was saying. It appeared that he had forgotten that the system was ours and we had decided on how we were going to evaluate who was an interested party and how we identified and scored aspects and impacts and which of those were significant. After a long discussion he accepted our point, he was clearly not happy at being challenged. My point being is that the system is yours and you decided what the significant aspects and impacts and what you are doing or going to about them.

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